Supporting Guidance: employer compliance: guidance by subject: commencing the compliance check: the intervention plan
The principles of Intervention Planning are mandatory and provide a strategic view of the case. It should:
- form a clear audit trail of how each of the risks identified before and during a compliance check are tackled, and
- what the final outcome is for each risk.
The Intervention Plan contains statistical information such as
- potential compliance revenue, or
- expected outcome
which must be completed.
The detail recorded in the plan must be proportionate to the risk and the work undertaken.
All compliance checks require a plan to:
- provide a strategy for proposed actions, and
- to record the outcomes.
A good intervention plan will provide a structure for:
- looking ahead to make sure all relevant information is obtained
- ensuring potential problems are anticipated
- taking the time to be clear about the actual risk of tax/NIC loss
- anticipating the likely response to the initial enquiry
- recording the steps that you would expect to take to address the risk
- planning what you intend to do and when you intend to do it
- maintaining focus on the progress of the case
- ensuring that the compliance check is cost effective and reduces the customer burden.
You should use the intervention plan to record
- specific risks to be addressed
- key steps planned to address those risks
- outcomes and conclusions
- compliance revenue
- where papers are kept.
For Caseflow cases the intervention plan is incorporated within the system.
- See Caseflow - Intervention plan.
- See Caseflow - Risks.
For ECS cases The Intervention Plan is accessible via SEES and should be maintained in the SEES Casebook. Help on completing the template is also available on SEES.
When completing the template in SEES you should:
- make sure that risks are clearly identified. Single word entries are not sufficient
- the potential compliance revenue or expected outcome should also be entered
- record how it is expected to respond to each identified risk (this may include tests selected from the Testbank). The response should be cost effective and consider the customers perspective
- record and comment upon tests/checks carried out to include any open points
- record the final conclusion for each risk with comments to support the result and details of any underpayment identified
record the substantive actions taken during the course of the compliance check, for example
- issue of formal notices
- review of records/meetings
- use of information powers
- appeals and related actions.
In all cases you should:
- update the Intervention Plan regularly so that it remains a comprehensive, up to date record of the compliance check and
- print off a hard copy if/when required.